SAFEGUARDS | Consumer ProductsNO. 081/20
In April 2020, in addition to the declaration of “none of the four regulated metals was intentionally introduced into the package or packaging component” and that the “total incidental presence of the four metals does not exceed the maximum allowable concentrations”, the Toxics in Packaging Clearinghouse (TPCH) added a new statement to the sample certificate of compliance saying: “no materials used to replace the regulated chemicals are present in a quantity or manner that creates a hazard as great or greater than the hazard created by the regulated chemicals.”
The Model Toxics in Packaging Legislation was adopted in 1989 by 19 US states. The model calls out basic requirements for disposable packaging. The model stipulates no intentional use of any amount of the four metals including lead, cadmium, mercury, and hexavalent chromium with a threshold level of 100 ppm for the total of the four metals combined.
The Model Toxics in Packaging Legislation and state laws require packaging suppliers, product manufacturers or distributors to issue a Certificate of Compliance. The certificate can be prepared based on the certificate of compliance for each packaging component from suppliers or analytical testing reports of four heavy metal content in the packaging. The model legislation requires packaging suppliers or product manufacturers to keep a copy of the certificate of compliance on file but records retention requirements vary by state. The new change strengthens the certificate of compliance with the statement that “the regulated chemicals are present in a quantity or manner that creates a hazard as great or greater than the hazard created by the regulated chemicals.”
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